Secured Asset Loan – Target Market Determination ("TMD")
A. About this TMD
Forward Finance Pty Ltd ACN 162 976 981 ACL No. 498369 (Forward Finance, we, us, our) is the issuer of the secured asset loan product described in this TMD (Product).This TMD is effective from 01/07/2022 and relates to the Product issued by Forward Finance.
This TMD describes:
• the class of customers that comprise the target market for the Product;
• any conditions or restrictions on how the Product may be issued; and
• events or circumstances which will cause us to review the TMD.
The TMD is not a replacement for the terms and any relevant supplementary materials which govern the Product. We encourage you to read and consider these documents, which are available on our website (www.forwardfinance.com.au), before deciding whether the Product is appropriate for you.
B. Product description
The Product is a secured asset loan which is intended to be used by consumers to finance the purchase of a motor vehicle or other asset.C. Attributes and target market
The TMD is required to disclose the key attributes of the Product and when they are likely to be consistent with the identified target market for the Product. The identified target market is based on the likely objectives, financial situation and needs of consumers.| Needs, objectives and financial situation of customers within the target market | Key product attributes |
|---|---|
| Require a loan to make a one-off purchase of a motor vehicle or asset over a fixed term. | The loan can be used to purchase motor vehicles or other acceptable assets. Acceptable assets
include motorcycle, caravan, campervan, camper or other road registrable trailer, boat and any other
acceptable assets registrable on the Personal Properties Securities Register. A loan term of up to 5 years. |
| Require certainty of interest rate costs and repayment amounts and the flexibility to make extra repayments and save interest during a fixed rate period. | Loan rates are fixed over the loan term. Additional repayments can be made without additional charge (additional payments cannot be redrawn). |
| Require a loan amount between $5,000 – $35,000 | A minimum loan amount of $5,000 and a maximum loan amount of $35,000. |
| A first-ranking security over the motor vehicle or acceptable asset can be provided. | Loan is secured by a first ranking security over the motor vehicle or acceptable asset. |
| Access to sufficient income to satisfy our credit assessment requirements and to meet the following repayments:
• principal amounts due • interest amounts due • application fee • risk fee • monthly fee | Regular scheduled repayments are required, including: • principal and interest repayments • application fee • risk fee • monthly fee |
| Eligibility may be available even if the customer has had previous credit history issues. | Customers with credit history issues are not automatically declined and their eligibility will be considered in accordance with our lending criteria. |
D. Eligibility
The Product is not available to people who:• are not Australian residents;
• are less than 18 years old;
• wish to use the finance to purchase an asset that is not an acceptable asset;
• wish to finance an asset that will be more than 25 years old at the end of the loan term;
• wish to purchase an asset that is subject to an existing security interest;
• are currently bankrupt; and
• do not otherwise meet our lending and eligibility criteria.
We consider the Product will likely be consistent with the identified target market of the Product, which is customers who are of good fame and have the capacity to service the loan. Customer credit history is assessed on a case-by-case basis. The Product may be offered to customers who have credit history issues from an event or circumstance which has been disclosed and adequately explained to us.
E. Distribution conditions
We apply the following distribution conditions so that the Product is likely to be issued to customers within its target market:| Needs, objectives and financial situation of customers within the target market | Key product attributes |
|---|---|
| Product is distributed by Forward Finance online or through its business team. Forward Finance holds an ACL. | • Forward Finance and brokers must either hold an ACL or be a credit representative of an ACL holder and authorised to distribute the loan to customers. This ensures they are regulated and required to comply with responsible lending and other legal obligations when recommending loan products to customers. • Forward Finance staff and brokers are made aware of the target market and must follow procedures criteria for loan eligibility as a condition of recommending the Product.. • Suitability and eligibility questions are implemented throughout the application process to identify applicants who are not within the identified target market prior to an offer being made to the customer.. • Forward Finance takes reasonable steps to ensure distribution is aligned with the target market.. |
| Product is distributed by brokers who hold an ACL or are representatives of an ACL holder. | |
| Customers may be referred to Forward Finance or accredited brokers by accredited referral partners with whom Forward Finance has a formal agreement. | • Referral partners operate in industries which offer acceptable assets to customers (i.e. car dealers). • Referral partners are restricted to merely referring customers to Forward Finance or accredited brokers. They cannot recommend or otherwise provide advice on the Product. • Customers are vetted using basic eligibility questions to determine whether a referral is appropriate. |
| Product may be marketed and general advice provided through both traditional and electronic mediums (i.e. such as Forward Finance’s website and social media). | It is intended that these channels may be available to persons who would not at the time qualify for the Product (i.e. minors). This is because the issue of the Product is subject to the remaining distribution conditions set out in this table, which is intended to ensure that the Product is only issued to customers within the intended target market. |
F. Review
We will review this TMD on an annual basis, or earlier if other circumstances prompt a review.A review will be undertaken immediately upon the occurrence of a review trigger, which is:
• the introduction of new products or major features;
• any material change to existing products or major features;
• a change to any law, regulatory guidance or industry code which has a material effect on the terms of the Product, including changes in responsible lending legislation and guidelines;
• a significant increase in default rates or hardship notices received within close proximity to loan origination;
• a significant number of complaints with respect to the Product;
• where there are significant dealings in the Product which is not consistent with the identified target market or this TMD; or
• where our reporting and monitoring procedures identify a need to review the TMD.
G. Reporting
We will collect and analyse information about the Product on an ongoing basis to determine whether the TMD remains appropriate. We will also collect the following information from distributors (other than Forward Finance) in relation to the Product:| Item | Description | Frequency | |
|---|---|---|---|
| Complaints | Complaints related to the Product, including:
• the number of complaints • the nature and circumstances of the complaints • whether consumer harm or detriment arises from circumstances which are the subject of the complaints | Quarterly | |
| Feedback | Feedback from distributors that the target market or
key product attributes may no longer be appropriate,
including about: • customer understanding of the risks, key terms, conditions or key attributes of the Product • fixed rates | Quarterly | |
| Dealings outside TMD | If a distributor becomes aware of a significant dealing in the Product or an issue with distributor conduct, that is not consistent with this TMD, they must notify Forward Finance as soon as practicable, and in any event within 10 business days after becoming aware. | Ongoing, as required. | |
| Other information requested | Any other information requested in writing by Forward Finance in relation to the Product. | Ongoing, as required. | |